Ohio Revised Code

Ohio Rev. Code § 3105.12 (2026)

Proof of marriage

✓ current as of May 2026
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(A) Except as provided in division (B) of this section, proof of cohabitation and reputation of the marriage of a man and woman is competent evidence to prove their marriage, and, in the discretion of the court, that proof may be sufficient to establish their marriage for a particular purpose.

(B)(1) On and after October 10, 1991, except as provided in divisions (B)(2) and (3) of this section, common law marriages are prohibited in this state, and the marriage of a man and woman may occur in this state only if the marriage is solemnized by a person described in section 3101.08 of the Revised Code and only if the marriage otherwise is in compliance with Chapter 3101. of the Revised Code.

(2) Common law marriages that occurred in this state prior to October 10, 1991, and that have not been terminated by death, divorce, dissolution of marriage, or annulment remain valid on and after October 10, 1991.

(3) Common law marriages that satisfy all of the following remain valid on and after October 10, 1991:

(a) They came into existence prior to October 10, 1991, or come into existence on or after that date, in another state or nation that recognizes the validity of common law marriages in accordance with all relevant aspects of the law of that state or nation.

(b) They have not been terminated by death, divorce, dissolution of marriage, annulment, or other judicial determination in this or another state or in another nation.

(c) They are not otherwise deemed invalid under section 3101.01 of the Revised Code.

(4) On and after October 10, 1991, all references in the Revised Code to common law marriages or common law marital relationships, including the references in sections 2919.25, 3113.31, and 3113.33 of the Revised Code, shall be construed to mean only common law marriages as described in divisions (B)(2) and (3) of this section.

Notes of Decisions
Cited in 35 cases (7 in the last 5 years), 1956–2026 · leading case: Hornbeck v. Hornbeck.
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Hornbeck v. Hornbeck (Ohio Ct. App. 2019). · cites it 4× “171 or R.C. 3105.12 (the statute pertaining to common law marriage) indicates the legislative history or intent.”
Williams v. Ormsby (Ohio 2012). · cites it 2× “2d 1235 (1988), and common-law marriages were prohibited in Ohio by statutory amendment after October 10, 1991, R.C. 3105.12(B)(1). D. Love and Affection Are Not Consideration for a Contract {¶ 40} Having rejected the cases that the court of appeals relied upon, we conclude that…”
State v. Burk (Ohio Ct. App. 2005). · cites it 2× “See R.C. 3105.12(A). Instead, it is the factual relationship of a common-law marriage that renders each party a “family or household member” for the purposes of Ohio’s domestic-violence statute.”
Drummer v. Drummer (Ohio Ct. App. 2012). · cites it 2× “R.C 3105.12(B)(1). However, relationships between a man and woman that attained common law marriage status prior to October 10, 1991 are recognized as valid and remain valid until terminated by death, dissolution, divorce, or annulment.”
Brian Gill v. Rodney Van Nostrand (D.C. 2019). “See Ohio Rev. Code Ann. § 3105.12 (B) (2019) ).”
Taylor v. Taylor (Ohio Ct. App. 2013). · cites it 2× “{¶ 52} This conclusion is consistent with R.C. 3105.12(B)(2), which states that “Common law marriages that occurred in this state prior to October 10, 1991, and that have not been terminated by death, divorce, dissolution of marriage, or annulment remain valid on and after…”
Caspar v. Snyder (E.D. Mich. 2015). “Code 1935, §§ 5700-5703); Ohio Rev. Code Ann. § 3105.12 (B)(2) (1991); 23 Pa.”
Dach v. Homewood (Ohio Ct. App. 2015). “Dach's First Assignment of Error {¶6} By Dach's first assignment of error, she contends the trial court erred as a matter of law in finding that the Ohio Constitution and R.C. 3105.12(B)(1) preclude the trial court from adopting a de facto date of commencement of the parties'…”
United States v. Long (N.D. Ohio 2014). · cites it 2× “Ohio Rev.Code § 3105.12. Long and Purucz-ky began dating in 1999, but apparently have chosen not to enter into a marriage relationship, which is certainly their option; however, Ohio law does not recognize a separate legal status for cohabitating unmarried persons.”
In Re Est. of Shepherd (Ohio Ct. App. 1994). · cites it 2× “Effective October 10, 1991, R.C. 3105.12(B)(1) prohibits common-law marriages in Ohio; however, under R.”
State v. Burkitt (Ohio Ct. App. 1993). “…were no longer married at the time of trial. 2 . Since October 10, 1991, they have been prohibited altogether. See R.C. 3105.12.”
Decarlo v. Est. of Maxwell (Ohio Ct. App. 2006). · cites it 2× “R.C. 3105.12(B)(1). However, common-law marriages that occurred prior to October 10, 1991 remain valid until terminated by death, dissolution, divorce, or annulment.”
Show all 35 citing cases →
— Ohio Rev. Code § 3105.12(A) — 1 case
State v. Burk (Ohio Ct. App. 2005). “See R.C. 3105.12(A). Instead, it is the factual relationship of a common-law marriage that renders each party a “family or household member” for the purposes of Ohio’s domestic-violence statute.”
— Ohio Rev. Code § 3105.12(B) — 3 cases
Hornbeck v. Hornbeck (Ohio Ct. App. 2019). “171 or R.C. 3105.12 (the statute pertaining to common law marriage) indicates the legislative history or intent.”
Ward v. Ward (Ohio Ct. App. 2012).
Jordan v. Jordan (Ohio Ct. App. 1996).
— Ohio Rev. Code § 3105.12(B)(1) — 18 cases
Williams v. Ormsby (Ohio 2012). “2d 1235 (1988), and common-law marriages were prohibited in Ohio by statutory amendment after October 10, 1991, R.C. 3105.12(B)(1). D. Love and Affection Are Not Consideration for a Contract {¶ 40} Having rejected the cases that the court of appeals relied upon, we conclude that…”
State v. Burk (Ohio Ct. App. 2005). “See R.C. 3105.12(A). Instead, it is the factual relationship of a common-law marriage that renders each party a “family or household member” for the purposes of Ohio’s domestic-violence statute.”
Drummer v. Drummer (Ohio Ct. App. 2012). “R.C 3105.12(B)(1). However, relationships between a man and woman that attained common law marriage status prior to October 10, 1991 are recognized as valid and remain valid until terminated by death, dissolution, divorce, or annulment.”
Dach v. Homewood (Ohio Ct. App. 2015). “Dach's First Assignment of Error {¶6} By Dach's first assignment of error, she contends the trial court erred as a matter of law in finding that the Ohio Constitution and R.C. 3105.12(B)(1) preclude the trial court from adopting a de facto date of commencement of the parties'…”
State ex rel. McDonald v. Indus. Comm. (Ohio 2023).
— Ohio Rev. Code § 3105.12(B)(1)(2) — 1 case
West v. West (Ohio Ct. App. 2022).
— Ohio Rev. Code § 3105.12(B)(2) — 11 cases
Taylor v. Taylor (Ohio Ct. App. 2013). “{¶ 52} This conclusion is consistent with R.C. 3105.12(B)(2), which states that “Common law marriages that occurred in this state prior to October 10, 1991, and that have not been terminated by death, divorce, dissolution of marriage, or annulment remain valid on and after…”
Drummer v. Drummer (Ohio Ct. App. 2012). “R.C 3105.12(B)(1). However, relationships between a man and woman that attained common law marriage status prior to October 10, 1991 are recognized as valid and remain valid until terminated by death, dissolution, divorce, or annulment.”
In Re Est. of Shepherd (Ohio Ct. App. 1994). “Effective October 10, 1991, R.C. 3105.12(B)(1) prohibits common-law marriages in Ohio; however, under R.”
Bevan v. Bevan, Unpublished Decision (6-2-2006) (Ohio Ct. App. 2006).
Decarlo v. Est. of Maxwell (Ohio Ct. App. 2006). “R.C. 3105.12(B)(1). However, common-law marriages that occurred prior to October 10, 1991 remain valid until terminated by death, dissolution, divorce, or annulment.”
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